Working conditions

The Clarks group of companies attaches real importance to the welfare not only of our own employees but also those employed by our suppliers.

At Clarks, we expect everyone engaged in the production of our products to be treated fairly, with dignity and respect, and for their work to be undertaken in conditions which are safe and not detrimental to their health.
The working condition standards we expect our suppliers to follow are set out in our Code of Practice. These standards apply to all those engaged in the production of our products. Our Code of Practice requires compliance with all local legal and regulatory requirements and the core labour principles of the United Nations International Labour Organization (ILO) conventions.

We support the right to freedom of association, and for collective bargaining in the negotiation of wages and encourage governments, and for employers to set wages that are appropriate for the needs of their workers and for the economic conditions in each country. Wages must be set at a level that meets both the immediate basic needs of workers and ensures the long term security of employment for those concerned. We are committed to ensuring that our suppliers pay their workers at least the legally required minimum wage.

We require suppliers to sign a copy of our Code of Practice to acknowledge they have read, understood and will comply with it. Compliance with our Code of Practice forms part of our template trading terms and conditions for the purchase of goods.

Clarks Code of Practice.

In an instance of non-compliance with the expected standards, we aim to work with the supplier in order to develop an Improvement Action Plan (IAP) that seeks to address root causes and provides sustained improvement. We believe that long term relationships offer the most benefit for our business and the people who make our shoes, so we do not just walk away from a supplier without first assessing what and how improvements could be made. However, in instances of continuous non-compliance and no evidence or willingness to adhere to an IAP, termination of the relationship remains the final sanction.

We have consulted UNICEF UK with regards to our remediation plan for any cases of child labour, as defined in our Code of Practice, that are identified in any of our suppliers. Clarks child labour remediation plan.

Understand

In common with other brands, our audits are conducted either by our in house specialist supplier audit team or by a third party audit service provider. Our in house specialists focus on our primary sourcing countries, which enables the team to develop a much stronger relationship with the factory and support an ongoing improvement process. In countries where we do not have our own resources, we utilise a third party audit service provider, whilst still maintaining our engagement with the supplier through the the supplier audit team.

Audits are normally conducted at any potential new supplier prior to the placement of an order for production. For existing suppliers, we use a tiered approach to the frequency of audits based on their previous audit results and management capability. Audits can be undertaken as either unannounced, semi-announced or announced depending on the location, type of relationship with the supplier and prior audit performance.
The audit process includes a review of all relevant documentation, interviews with management & workers and an inspection of all areas of the factory site.

Audit Activity during 2018

250 social audits were conducted across our entire supply base during 2018. Of these, 210 were undertaken in China, India and Vietnam by our own internal audit team, while an additional 40 audits were undertaken by 3rd party audit service providers.

In addition to the social audits conducted, 53 security audits were undertaken at finished goods suppliers in support of customs requirements.

Improve

Undertaking audits does not in itself change or improve the working conditions in our suppliers, rather they are the starting point in an ongoing process of improvement. What makes the difference is how the information gained through the audit is used to address any findings and make a positive change for the benefit of those working in each factory. We do this in a number of ways.

For all findings that are identified through the audit, we require the supplier to complete an Improvement Action Plan, which identifies the root cause of the finding, what action will be taken to address it, who is responsible and when it will be completed. We use this information in subsequent follow ups to verify that appropriate action has been taken to ensure sustainable improvement is made.

We provide training inputs to our suppliers, both formal and informal, and delivered either by ourselves or through working with other partners and providers, including supporting attendance at publicly available events. These have covered topics such as children's rights, transparency, wages and benefits, and health & safety, including fire safety, chemical management and exposure control.

The working conditions within supplier facilities and the improvement made, as assessed through our audit process, are included in the performance evaluation of our suppliers.

Collaborate

At Clarks, we believe strongly in working collaboratively with others to effect change and bring about improvements within the footwear supply chain. For example, we have worked with teams from other brands to undertake joint auditing of shared suppliers, which allows the factory to make better use of their resources to make improvements.

Following our membership of the Global Social Compliance Programme (GSCP), which is operated by the Consumer Goods Forum (CGF), we have maintained our engagement now that it has been incorporated into the Sustainability work stream of the CGF by becoming members of the CGF. A global cross-industry network, the CGF Sustainability Committee aims to drive harmonisation, convergence and best-practice sharing for a better and more sustainable supply chains.

Clarks fully supports the CGF resolution on forced labour and the adoption of the three Priority Industry Principles; Every worker should have freedom of movement; No worker should pay for a job; No workers should be indebted or coerced to work.

Find more information about the Consumer Goods Forum here.

In 2016, we became a member of the Mekong Club, a membership-based organisation that works with companies to help them take steps to eradicate slavery from their business through industry-specific working groups. We are proud to be one of the first brands to commit to the Mekong Club Business Pledge against Modern Slavery. Find out about the Mekong Club and the Business Pledge here.

In 2018, we became a member of the Slave Free Alliance to further support our work to prevent and mitigate the risk of forced labour in our suppliers. Find out further information on the Slave Free Alliance here.